Pre migration planning

Mr. Abdullah, an executive working for a big oil company in Kuwait and also resident in Kuwait (0% income tax) is sent by his employer to Germany to become the CEO European operations of his company. It is expected that he will stay in Germany for a long period of time (at least 8 - 10 years) and he takes his family with him to Germany.

Mr. Abdullah is concerned about the high personal income tax rates in Germany (up to 48.5%). He wonders whether his exposure to German tax can be mitigated as a result of pre-migration tax planning.

Suggested solution:

Mr. Abdullah might consider to transfer funds and other property owned by him to a trust established by him prior to moving to Germany. The trust will then administer the property for the beneficiaries as determined by Mr. Abdullah.

From a point of view of German tax law, Mr. Abdullah himself should not be one of the beneficiaries, at least not as long as he is a tax resident of Germany. The same is true for the other beneficiaries.